Jurisdiction(s):
United Kingdom

Tax due diligence checklist for selecting a holding company jurisdiction: treaty access, withholding, substance, CFC/anti-avoidance, distributions, capital gains, finance costs, rulings and reforms (ATAD 3, BEPS Pillar 2)

Published by a LexisNexis Tax expert

Checklists

Evaluating a holding company jurisdiction

This Checklist provides a practical template for assessing a prospective holding company jurisdiction from a tax standpoint and perspective. It should be carefully tailored to the specific deal at hand; to illustrate, rules on interest withholding are generally immaterial where no interest payments are anticipated in the circumstances. For a Practice Note that explains the general tax concerns, issues and aims summarised in this Checklist when selecting the location of a holding company or an intermediate holding vehicle for an international enterprise (or a segment of such an enterprise) or a fund, consult Practice Note: Holding company jurisdictions—tax considerations...

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Andrew Howard

Ropes & Gray

Andrew (Andy) Howard is a partner in the tax and benefits group, focusing on UK corporate tax and international tax matters. He has more than 15 years' experience working on a wide spectrum of complex UK tax issues. Andy's practice focuses on all types of transactions involving investment funds, including private equity, finance, special situations, real estate, and fund formation, but also includes UK and international M&A, structured finance, derivatives, stock lending and general advisory work.Mentioned in Legal 500, Andy is a regular contributor to leading UK tax publications and has presented a number of seminars on developments in UK tax law. He also focuses on cross-border and international tax matters, co-ordinating advice with counsel in a wide range of jurisdictions to provide fully joined-up advice on the tax effects of clients' transactions. He takes pride in providing clear and concise advice on...

Web page updated on 20/05/2026

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